Social Accountability Policy

HAMILTON BEACH'S SOCIAL ACCOUNTABILITY POLICY

Hamilton Beach Brands, Inc. is committed to achieving the highest standards of ethical and legal conduct for itself and its business partners. Hamilton Beach carefully selects its manufacturing partners, developing long-term relationships with people committed to our rigorous standards. These high standards include the working conditions under which our products are produced.

We are industry leaders who have worked to enhance workplace conditions within our manufacturing partners' factories. As with product safety standards, we have tried to raise the social accountability bar for our entire industry. Our agreements with suppliers require them to adhere to basic human rights principles. In addition, we have developed a detailed Social Accountability Policy to which all of our suppliers must adhere. We first developed such a policy in 2002.

We retain an independent third-party to audit our suppliers' conformance to the Social Accountability Policy. The requirements of the Social Accountability Policy generally provide greater worker protection than required by the applicable local laws and regulations in the jurisdictions where product is produced.

Summary of Key Provisions of Our Social Accountability Policy:

All suppliers must operate in full compliance with all applicable laws, rules and regulations of the countries where they manufacture, including but not limited to those related to labor, employee health and safety and the environment.

Where our Social Accountability Standard differs from local laws, our suppliers must follow the more stringent standard.

Zero Tolerance Provisions

Child Labor – no employment of anyone under age 16 or younger than age of completing compulsory education

Forced Labor – no forced, prison or indentured labor

Harassment or Abuse – no physical, sexual, psychological, or verbal harassment or abuse

Compensation and Benefits must meet or exceed minimums set by local laws, with premiums paid for overtime work

Hours of Work and Overtime – maintain reasonable work hours, including minimum time-off every week

Working Conditions/Health & Safety – must meet or exceed minimums set by local laws, with adequate facilities and protections from exposure to hazardous conditions or materials

Environment – must meet or exceed minimums set by local laws.

CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT OF 2010The California Transparency in Supply Chains Act of 2010 is intended to inform consumers whether goods are the product of human trafficking and slavery. The Act requires manufacturers and retailers who do business in California and have more that $100 million in worldwide gross receipts to "disclose their efforts to eradicate slavery and human trafficking from their direct supply chain for tangible goods offered for sale." While the Act addresses only one aspect of social accountability, Hamilton Beach fully supports the intent of this law.

Hamilton Beach engages in verification of suppliers to evaluate and address various risks, including but not limited to human trafficking and slavery.

Hamilton Beach conducts audits of suppliers to evaluate their compliance with our social accountability standards, including but not limited to prohibitions against trafficking and slavery.

Hamilton Beach requires direct suppliers to certify that materials incorporated into their products comply with the laws of the countries where they are being sold, including but not limited to laws prohibiting slavery and human trafficking.

Hamilton Beach maintains internal accountability standards and procedures for employees and contractors who fail to meet our standards, including but not limited to prohibitions against slavery and trafficking.

Hamilton Beach provides training on social accountability standards to employees with direct responsibility for supply chain management, including but not limited to prohibitions against human trafficking and slavery, so as to achieve the highest standards of legal and ethical conduct for itself and its business partners and ensure compliance with all laws.

CUSTOMS-TRADE PARTNERSHIP AGAINST TERRORISM (CT-PAT)Hamilton Beach has been part of CT-PAT since July 2005. In partnering with the Department of Homeland Security, Hamilton Beach's supply chain has been evaluated by US Customs and Border Protection as meeting the "highest level of cargo security."

CONFLICT MINERALS

Hamilton Beach will comply with the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Act) and regulations enacted pursuant to the Act for sourcing Conflict Minerals and supply-chain due diligence according to the Organization for Economic Cooperation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas. “Conflict minerals” are defined as columbite-tantalite, cassiterite, gold, wolframite, or their derivatives, and any other mineral/derivatives determined by the US Secretary of State to finance conflict in the Democratic Republic of the Congo or any adjoining country (the DRC).

Hamilton Beach is committed to sourcing components and materials from companies that share our values regarding respect for human rights, integrity and environmental responsibility. We will neither tolerate nor in any way facilitate the serious abuse of human rights associated with the extraction, transportation and trading of conflict minerals in the DRC.

To this end, Hamilton Beach has developed processes and procedures to comply with the Act, which include communicating our conflict minerals requirements to our suppliers and working with them to comply with the Act. In turn, each supplier is to inform its supply chain of our requirements and perform the necessary due diligence to ascertain the source of any conflict minerals in the products it provides to us.